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Press Release

Former Heads of New York-Based Non-Governmental Organization Plead Guilty to Conspiring to Bribe Elected Officials of the Marshall Islands

For Immediate Release
Office of Public Affairs

Two Marshallese nationals pleaded guilty today to conspiring to pay bribes to elected officials of the Republic of the Marshall Islands (RMI) in exchange for passing certain legislation.

According to court documents, beginning in or around 2016 and continuing until at least August 2020, Cary Yan, 50, and Gina Zhou, 34, the heads of a New York-based non-governmental organization (NGO), conspired with others in connection with a multi-year bribery scheme. Yan and Zhou offered and paid tens of thousands of dollars in bribes to elected RMI officials – including, among others, members of the RMI legislature – in exchange for supporting legislation creating a semi-autonomous region within the RMI called the Rongelap Atoll Special Administrative Region (RASAR) that would benefit the business interests of Yan, Zhou, and their associates. Yan and Zhou carried out the bribery and money laundering scheme using the New York NGO, including the physical use of its headquarters in Manhattan, to meet with and communicate with RMI officials. 

In November 2020, Thai authorities arrested Yan and Zhou in Thailand at the request of the United States pursuant to the U.S.-Thailand extradition treaty, and following court proceedings, the Thai government extradited Yan and Zhou to the United States on Sept. 2.

Yan and Zhou each pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA). They each face a maximum penalty of five years in prison. A sentencing date has not yet been set. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

Assistant Attorney General Kenneth A. Polite, Jr. of the Justice Department’s Criminal Division, U.S. Attorney Damian Williams for the Southern District of New York, and Assistant Director-in-Charge Michael J. Driscoll of the FBI New York Field Office made the announcement.

The FBI investigated the case. The Royal Thai Government, the U.S Department of State’s Diplomatic Security Service, the Embassy of the United States in Bangkok, and the Justice Department’s Office of International Affairs provided substantial assistance in securing the arrest and extradition of the defendants.

Assistant Chief Gerald M. Moody Jr. and Trial Attorney Anthony Scarpelli of the Criminal Division’s Fraud Section and Assistant U.S. Attorneys Hagan Scotten, Lara Pomerantz, and Derek Wikstrom for the Southern District of New York are prosecuting the case.

The Fraud Section is responsible for investigating and prosecuting FCPA matters. Additional information about the Justice Department’s FCPA enforcement efforts can be found at

Updated December 2, 2022

Foreign Corruption
Press Release Number: 22-1289